With reference to the provisions of Regulation (EU) 2019/2088 of the European Parliament and of the Council of 27 November 2019 relating to the disclosure on sustainability in the financial services sector, Cassa Lombarda believes that at present the sustainability risks11 are not overall significant. in its investment decision-making processes and in its investment or insurance consultancy, based on the nature of the management and consultancy approach characterized by a wide diversification of risk factors, a low concentration on single issuers and extensive use of alternative strategies. However, the Bank has launched a dedicated project with the aim of evaluating the adoption of a sustainability risk integration policy, also in relation to the revision and expansion of its catalog of services with a section of solutions conceived to natively integrate sustainability risks as a distinctive element of the value proposition in one’s management or advisory strategy. In this sense, it is highlighted the availability already from 2018 of an Asset Management line – Digital Revolution – whose management policy provides for the selection of shares also on the basis of an ESG scoring provided by an external provider. Likewise, at present the main negative effects of investment decisions on sustainability factors are not taken into consideration, given the novelty of the subject and the need to develop a valid and adequate methodology based on a non-financial information set. public and standardizable. It is the bank’s intention to carefully evaluate the opportunity to acquire data, develop tools and define processes for this purpose.
Depending on the possible integration of sustainability risks, the remuneration policies will be updated accordingly, on the occasion of the annual review and approval of the document that governs them.
1 – Sustainability risk is an environmental, social or governance event or condition which, if it occurs, could cause a significant actual or potential negative impact on the value of the investment (Article 2 – EU Regulation 2019/2088).